OSHA Announces Alignment of Haz Comm Standard with the Globally Harmonized System of Classification and Labeling of Chemicals

March 20, 2012
Secretary of Labor Hilda L. Solis and Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels held a teleconference March 20 to announce the final rule for the long-awaited update to OSHA’s Hazard Communication standard that aligns it with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

Noting that the Hazard Communication standard, published in 1983, was referred to as “the right to know,” Solis announced that the revised Hazard Communication standard is “the right to understand.”

Haz Comm 2012, as it is known at the agency, communicates information about chemical hazards in the workplace “more simply, clearly and effectively,” said Solis. It “empowers [workers] with the best information about the chemicals they handle in the workplace,” she added.

"Exposure to hazardous chemicals is one of the most serious threats facing American workers today," said Solis. "Revising OSHA's Hazard Communication standard will improve the quality and consistency of hazard information, making it safer for workers to do their jobs and easier for employers to stay competitive."

OSHA’s Haz Comm standard requires chemical manufacturers and importers to evaluate the hazards of the chemicals they produce or import, and prepare labels and safety data sheets to convey the hazard information to their downstream customers. It also requires all employers with hazardous chemicals in their workplaces to have labels and safety data sheets for their exposed workers, and train them to handle the chemicals appropriately.

The American Industrial Hygiene Association already has announced its support of the update. “After more than 25 years since adoption of the HCS, AIHA is pleased that OSHA has finalized this update and fully supports provisions that update the development and distribution of material safety data sheets for hazardous chemicals,” said AIHA President Elizabeth Pullen, CIH. “The new safety data sheets not only greatly improve the quality of MSDSs by establishing a harmonized structure and meaningful recommendations of content but will improve the protection provided to workers, employers and chemical users.”

The major changes to the standard announced on March 20 include:

  • Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.
  • Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram and hazard statement for each hazard class and category. Precautionary statements also must be provided.
  • Safety data sheets: Now will have a specified 16-section format.
  • Information and training: Employers are required to train workers by Dec. 1, 2013 on the new labels’ elements and safety data sheets’ format to facilitate recognition and understanding.

Combustible Dust

OSHA has not provided a definition for combustible dust to the final Haz Comm standard, given ongoing activities in the specific rulemaking, as well as in the United Nations Sub-Committee of Experts on the GHS (UN/SCEGHS). However, guidance is being provided through existing documents, including the Combustible Dust National Emphasis Program Directive (CPL 03-00-008), which includes an operative definition, as well as provides information about current responsibilities in this area. In addition, there are a number of voluntary industry consensus standards (particularly those of the NFPA) that address combustible dust.

In the final Haz Comm standard, combustible dust hazards must be addressed on labels and safety data sheets. Label elements are provided for combustible dust in the final standard, and include the signal word "warning" and the hazard statement, "May form combustible dust concentrations in the air."

Impact of Revised Hazard Communication Standard

OSHA estimates that over 5 million workplaces in the United States would be affected by the revised Hazard Communication standard. These workplaces employ approximately 43 million workers who potentially could be exposed to hazardous chemicals. Included among these 5 million workplaces are an estimated 90,000 establishments that create hazardous chemicals; these chemical producers employ almost 3 million workers.

The revised standard's total cost, an estimated $201 million a year on an annualized basis for the entire United States, is the sum of four major cost elements:

  • OSHA estimates that the cost of classifying chemical hazards in accordance with the GHS criteria and revising safety data sheets and labels to meet new format and content requirements would be $22.5 million a year on an annualized basis.
  • OSHA estimates that training for employees to become familiar with new warning symbols and the revised safety data sheet format under GHS would cost $95.4 million a year on an annualized basis.
  • OSHA estimated annualized costs of $59 million a year for management to become familiar with the new GHS system and to engage in other management-related activities as may be necessary for industry's adoption of GHS.
  • OSHA estimated annualized costs of $24.1 million for printing packaging and labels for hazardous chemicals in color.
OSHA offers a Safety and Health Topics page for Hazard Communication that includes a definition of hazard communication, lists the OSHA standards that apply, discusses GHS and much more.

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